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The federal government should push colleges to improve the criminal justice response to rape, de-emphasize internal judicial boards, put in place bystander intervention and risk reduction programs, and ensure comprehensive care for victims, RAINN advised a new White House task force charged with creating a plan to reduce rape on college campuses.

In 16 pages of recommendations, RAINN urged the task focus to remain focused on the true cause of the problem. “In the last few years, there has been an unfortunate trend towards blaming “rape culture” for the extensive problem of sexual violence on campuses. While it is helpful to point out the systemic barriers to addressing the problem, it is important to not lose sight of a simple fact: Rape is caused not by cultural factors but by the conscious decisions, of a small percentage of the community, to commit a violent crime,” said the letter to the task force from RAINN’s president, Scott Berkowitz, and vice president for public policy, Rebecca O’Connor.

President Obama appointed the White House Task Force to Protect Students from Sexual Assault in January, giving it 90 days to recommend improvements colleges should make. The task force includes representatives from the White House, Justice Department, Education Department, Health and Human Services and other federal agencies.

RAINN’s recommendations pointed to research that suggests that more than 90% of college rapes are committed by about 3% of college men (reliable research about female perpetrators is harder to come by). Based on that pattern of assaults by repeat offenders, RAINN stressed the importance of treating sexual assaults on campuses as the serious crimes that they are, and ensuring that there are meaningful consequences.

RAINN also stressed the need to de-emphasize colleges’ internal judicial boards. “The FBI, for purposes of its Uniform Crime Reports, has a hierarchy of crimes — a ranking of violent crimes in order of seriousness. Murder, of course, ranks first. Second is rape. It would never occur to anyone to leave the adjudication of a murder in the hands of a school’s internal judicial process. Why, then, is it not only common, but expected, for them to do so when it comes to sexual assault,” the letter asked. “The simple fact is that these internal boards were designed to adjudicate charges like plagiarism, not violent felonies. The crime of rape just does not fit the capabilities of such boards.”

For prevention programs, “RAINN recommends a three-tiered approach when it comes to preventing sexual violence on college campuses,” the letter noted. A prevention campaign should include the following elements:

1. Bystander intervention education: empowering community members to act in response to acts of sexual violence.

2. Risk-reduction messaging: empowering members of the community to take steps to increase their personal safety.

3. General education to promote understanding of the law, particularly as it relates to the ability to consent.

Other recommendations included getting colleges to:

Investigate every claim of sexual assault reported.

Partner with local law enforcement on each investigation, starting immediately after a crime is reported.

Ensure all victims and survivors — including male survivors and the LGBT community — have access to comprehensive support systems (campus, local, and national) and forensic medical exams.

Educate the campus community on their rights and roles in the wake of sexual violence.

RAINN also recommended that the federal government:

Spearhead rigorous, continuing research to assess what messaging is (and is not) working to further the overall goal of decreasing sexual violence on campus and taking rapists off campuses and streets.

Impose meaningful sanctions for violations of federal law.

Support innovative approaches and technologies to ensure there is transparency around this issue, and to enhance schools’ ability to respond to and prevent sexual violence.

Require all colleges and universities to disseminate the phone number and URL for the National Sexual Assault Hotline (800-656-HOPE and online.rainn.org) and other support resources to all community members.

RAINN’s letter to the task force also included ideas drawn from a survey it issued to 100,000 supporters, requesting input from the community on this issue. RAINN received an overwhelming number of responses from survivors, victim advocates, law enforcement personnel, campus officials and faculty members, prosecutors, and others, said O’Connor.